Hinton v. Alabama, 571 U.S. 263

The issue was whether trial counsel was ineffective. Trial counsel’s failure to request additional funding in order to replace an expert he knew to be inadequate because he mistakenly believed that he had received all he could get under Ala. Code § 15-12-21(d) constituted deficient performance. Specifically, trial counsel knew he needed additional funding to present an adequate defense, yet he failed to make even the cursory investigation of the state statute providing for defense funding for indigent defendants that would have revealed to him that he could have received reimbursement not just for $1,000, but for any expenses reasonably incurred. In the instant case, the inadequate assistance of counsel was the inexcusable mistake of law, i.e., the unreasonable failure to understand the resources that state law made available to him, that caused counsel to employ an expert that he himself deemed inadequate. As for the prejudice prong of the Strickland analysis, a remand was necessary because no court had yet applied the proper inquiry to the facts of the case.